|Received:||7/13/2006 7:53:14 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
|Attachment:||522418-09022.pdf Download Adobe Reader|
Comments:I am a Quixtar Independent Business Owner (IBO). I started by business in 1997. My business provides a great secondary source of income, professional development and personal growth as a result of the relationships with other IBOs, my sponsoring Upline and the Quixtar business team and parent company. When I was first exposed to this business opportunity, I received more than adequate information to make an informed business decision. Likewise, I provide that same information to the individuals that I bring onto my business team. My new IBOs know that this is not a “get rich quick scheme,” that hard work and long term goals are involved in building a successful Quixtar business. A new IBO can expect to spend about $125.00 to register their business, get some starter products and information to start building their business team. Specific issues related to the proposed rule that I feel pose a significant undue and unfair burden on my business and the businesses of new people that I bring onto my business team and are particularly relevant to how I run my business are: 1. The requirement of a seven-day waiting period: Waiting seven days to register a new business is a huge handicap to the new IBO. Often times I travel to help and work with new IBOs. If I am unable to start their business while I am their helping them they stand to fail at a significant rate. When I am there helping them I can teach and instruct and give them my experience. Waiting seven days will deny the new IBO that helpful experience to get started properly with the greatest chance for success. Likewise, the new IBO will not be able to register new IBOs at the same time and this will stunt their businesses’ growth and chance for profitability. Often times more than one IBO will get registered at a time as a team starts to develop around that new IBO. (This will no longer be the case if this seven day period is enforced.) This rule will greatly hurt and handicap the new IBO as well as the sponsoring IBO. 2. The requirement to provide references: I consider it a violation of my privacy and that of my business team to have to provide name, address, and phone numbers of IBOs to prospects. Because of the number of IBOs in any given area, this rule would place an unfair and unusual hardship upon the sponsoring IBO to come up with such information and maintain an accurate roster of IBOs in an area. When traveling and servicing distant teams this would be virtually impossible to comply with, thus violating interstate commerce laws and my ability to conduct business out side of a very small localized area. Currently, new IBOs get opportunities to meet other IBOs when they go to open meetings held in their area to get information about the business opportunity. 3. The requirement to provide a "litigation list": A disclosure document requiring a list of all litigation involving the seller, ...within the past 10 years," is a huge and unfair burden to impose on this market place and my business. As a retailer of goods, I do not find any other enterprise I frequent that has such a requirement to do business. This rule is without question a completely unacceptable requirement to conduct business. 4. The requirement for specific earnings disclosures: Currently I use a disclosure form and explanations about the income potential of a Quixtar business with prospects today. (These items are detailed such as the average monthly gross income of IBOs, on the FTC approved SA-4400 form, etc.) I believe that this additional proposed rule would over burden the IBO and prove to be irrelevant to the prospect investigating the Quixtar opportunity. 5. The requirement for financial substantiation: It would be completely inappropriate and a violation of my privacy to be required to disclose my personal finances to a prospect. I do not divulge any information about my personal finances and business income to prospects when presenting the Quixtar plan.